rather than collecting top-up tax from constituent entities (CEs) that may own join ventures. The rationale for this is to provide certainty in meeting the QDMTT Safe Harbour and to not utilize the switch off rule in this regard.
its introduction has now been confirmed. The significance of the QDMTT Safe Harbour is that it effectively gives the jurisdiction operating the QDMTT the final decision on whether an MNE Group must pay top-up tax within that jurisdiction